You can appeal and talk to payment processors today, and they essentially tell you that your category of transactions has high fraud rates or exposes them to le

You can appeal and talk to payment processors today, and they essentially tell you that your category of transactions has high fraud rates or exposes them to legal risk until you do XYZ impossible or arduous things to mitigate the liability or risk. They will use the same motte that they use now to justify their bailey reality.